SEPA
               UniMdStMM
               Envtromnemcl Protection
               Agency
 Off ic« of
 Soltd Wast* and
 Em*rg*ncy R*spon»*
                DIRECTIVE NUMBER: 9444.01(84)

                TITLE:  Clarification of the Listings for Metal Heat
                     Treating Wastes F010, F011, and F012
               APPROVAL DATE:  3-5-84

               EFFECTIVE DATE:  3-5-84

               ORIGINATING OFFICE:

               12 FINAL
    Office of Solid Waste
               D DRAFT

                 STATUS:
I  1
[  1
[  ]
[
A- Pending OMB approval
B- Pending AA-OSWER approval
C- For review &/or comment
                            ]  D- In development or circulating
               REFERENCE (other documents):
             headquarters
  OSWER      OSWER      OSWER
VE   DIRECTIVE   DIRECTIVE   Dl

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PART 261  SUBPART D - LISTS
                                                DOC:  9444.01(84)
Key Words:    Cyanide

Regulations:  40 CFR 261.31

Subject:
Addressee:
Date:

Summary:
Clarification of the Listings for Metal Heat Treating Wastes
F010, F011, and F012

James H. Scarbrough, Chief, Residuals Management Branch, Air
and Waste Management Division, Region IV
Originator:   Matthew A. Straus, Acting Chief, Waste Identification Branch

Source Doc:   #9444.01(84)
3-5-84
     If a metal heat treating process uses any form of cyanide—complex or
free—the process is covered by the hazardous waste listings F010, F011, and
F012.

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                                                           9444.01

xflarificat loir' of the Listings Tor Metal Heat Treating "Wastes
*010,\Fvll, and F012.  v         -•--..

Matthew A. Straus, Acting enter
Waste Identification Branch  {WH-562J
    *>•*         "    --*"'     v      *

"James- E. Scarbrough, Chief     t
Residuals Management Branch
Air & Waste Management Division
Region IV "                  '*  ""


     This memorandum is  in  response to your question
regarding the scope of the  cyanide listings for metal heat
treating operations (EPA Hazardous Waste Nos.  P010, F011,
and P012).  In particular,  you asked whether the  form of
cyanide (i.e., complex cyanide  or free cyanide) was germane
in determining whether one  had a listed waste.  In short,
the answe-F^ls no.  In  listing these'wastes as  hazardous,
the Agency was (and is still) concerned with the  management
(or mismanagement) of  cyanide wastes (both complex cyanide
mnd cyanide salts).  If  the  Agency felt that a distinction
was necessary, it would  have done so in the listing.  For
example., SPA Hazardous Waste No. F012 would have  been listed
'as follows:"  V                                          .

.  " ,"Quenching wastewater  treatment sludges from metal
 •  .  heat treating operations where complexed  cyanides are
.  -.   ..used in  the process  (except for precious metals  heat '...
    /treating quenching  wastewater treatment sludges)."   -

In addition,  you should  be  aware .that the  form of cyanide
often changes during the heat treating operation  or subsequent
treatment; therefore,  although  you may begin with cyanide
salts (free cyanide) your waste may be primarily  Complex
cyanide.  The waste listings take this into, account by
differentiating between  the form of cyanide present in the
waste (i.e., .only cyanide-salt  containing wastes  (free
•.cyanides) are listed as  posing  a reactivity hazard).
  •.    - •        -     , ...•   .   ^   .      •.-.•-....
• . .»/   •  '.       •  -    ,-    *   X"'    •   '  T" «'
   J" -Furthermore, it should be  noted that  although complex
cyanides'are  less toxic  than free1 cyanides, complex cyanide-  ••»
bearing wastes are of  concern because of their potential to
undergo photodecomposition  to form toxic hydrogen cyanide
and free cyanide decomposition  by-products.   (See Listing
Background  Document for  Cyanide Wastes, Response  to Cerements
Section, Comment No. 3 for  more details.)!./  Therefore,  if
the metal heat treating  process uses cyanides  in  any  form,
 the process is covered by  the hazardous waste  listings.
 V This document is included in the document $$261.31 and
    261.32 - Listing of Hazardous Wastes (Pinalization of
    May 19, 1980 Hazardous Waste List),  #1941.28 November 14,
    1980.

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